Tax

Representative Matters

Representing a foreign-based multinational retail company in a competent authority matter involving a Swiss affiliate’s sale of tangible goods to U.S. subsidiary.
Representing a U.S.-based hospitality company in bilateral U.S.-Swiss and unilateral advance pricing agreements related to high-value services.
Advised a multinational software company on transfer pricing options to restructure its Luxembourg intellectual property management company in light of changes in local and European Union law and under the BEPS initiative (129 subsidiaries in 38 countries).
Represented technology companies in IRS Exam, IRS Appeals, and competent authority proceedings concerning buy-in royalty and cost-share payments; when the IRS proposed designating one company’s cost-sharing case for litigation, we succeeded in resolving the matter without litigation.

AT&T Advertising, L.P. v. United States, No. 1:16-cv-00272- RTH (Fed. Cl. filed Feb. 26, 2016) (section 199 deduction).
BrokerTec Holdings Inc. v. Commissioner, 117 T.C.M. (CCH) 1146, rev’d, 967 F.3d 317 (3d Cir. 2020).
Vesta Corporation v. Commissioner, Nos. 26847-16, 26503-17 (T.C. Nov. 13, 2018) (section 199 deduction for software).
Trusted Media Brands, Inc. v. United States, 2017-2 U.S.T.C. ¶ 50,359 (S.D.N.Y. 2017), aff’d, 899 F.3d 175 (2d Cir. 2018) (statute of limitations applicable to claim for refund based on change to deduction of foreign taxes paid).
District of Columbia Office of Tax & Revenue v. BAE Systems Enterprise Systems, Inc., 56 A.3d 477 (D.C. 2012) (tax credits and incentives for qualified high technology companies).